Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) Reconsideration and Exception & Extension

This webpage provides information and updates related to the reconsideration and exception and extension process for the SNF QRP. You will also find guidelines for submitting reconsideration requests and requests for exceptions and exemptions.

SNF QRP: Natural Disaster Protocol

For disasters impacting the Post-Acute Care (PAC) QRPs, a disaster-specific memo will be posted to the Downloads section below with additional information, including impacted counties and quality reporting quarters.

Updates

Reporting Exception Granted Due to Hawaii Kona Low Weather Systems and Commonwealth of the Northern Mariana Islands Super Typhoon Sinlaku

The Centers for Medicare & Medicaid Services (CMS) is granting extraordinary circumstance exceptions¹ under certain Medicare quality reporting and value-based purchasing programs to providers and facilities located in areas affected in the state of Hawaii by the Hawaii Kona Low Weather Systems, and in the Commonwealth of the Northern Mariana Islands by Super Typhoon Sinlaku, as identified by both Department of Health and Human Services (HHS) Public Health Emergency (PHE) declarations (PHE | Hawaii - Severe Storms; PHE | Northern Mariana Islands – Super Typhoon Sinlaku) and the Federal Emergency Management Agency (FEMA) major disaster declarations (FEMA | HI Major Disaster Declaration (4909); FEMA | Northern Mariana  Islands Major Disaster Declaration (4910)), to support these providers and facilities which may require the focusing or redirecting of resources toward accommodating circumstantial care needs of their patients and addressing potential infrastructure challenges affecting their healthcare operations.

Affected areas covered by these exceptions are detailed on the Designated Areas: Disaster 4909 and Designated Areas: Disaster 4910 pages, under the section Public Assistance, designations PA-A and PA-B, of the FEMA website. If FEMA expands the major disaster declaration to include additional affected areas at a later date and it is operationally feasible, CMS will likewise extend reporting requirement exceptions to accommodate these areas but will not necessarily publish updated communications.

At the time of this communication, the exceptions being granted are for the reporting requirements and deadlines as detailed in the table below:

1 The terminology “exception” is used as a general term intended for ease of reference to collectively refer to extraordinary circumstance exception (ECE) policies established under separate programs and may not be consistent with the specific terminology established under each individual program.

Additional Reporting Requirement Exceptions

Providers and facilities located within a designated area listed in the FEMA disaster declaration who seek an exception for a reporting requirement not covered by this table may request an individual exception using the applicable ECE request process for the respective program(s). CMS will assess and decide upon each ECE request on a case-by-case basis.

Merit-based Incentive Payment System (MIPS)

In addition to the above table, the MIPS Automatic Extreme and Uncontrollable Circumstances (EUC) policy will be applied at the individual level to MIPS eligible clinicians identified as located in the aforementioned affected areas. Additional information on this policy can be found in the 2026 MIPS Automatic EUC Factsheet.

Exception and Extension Requests Overview

The Centers for Medicare & Medicaid Services (CMS) provides Skilled Nursing Facilities (SNFs) an opportunity to request an exception or extension from the program’s reporting requirements in the event they were unable to submit quality data due to extraordinary circumstances beyond their control. SNFs affected by a natural or man-made disaster or other extraordinary circumstances may request an exception or extension by filing an Extraordinary Circumstance request.

Submission Exception and Extension Process in Cases of Disaster or Extraordinary Circumstances

All SNFs requesting an exception or extension must submit the request within ninety (90) days of the event. CMS may grant the exception or extension for one or more quarters. CMS may also grant the exception or extension to SNFs that have not requested one when an extraordinary circumstance, such as an act of nature, affects an entire region or locale. CMS will communicate through routine channels when such determination is made.

SNFs must request an exception or extension via email with the subject line, “Disaster Exception or Extension Request”, and send it to: SNFQRPReconsiderations@cms.hhs.gov. The email must include the following information:

•            SNF CMS Certification Number (CCN)

•            SNF Business Name

•            SNF Business Address

•            CEO or CEO-designated personnel contact information including name, email address, telephone number, and physical mailing address, i.e. not a post office box

•           Description of the event (examples provided above) associated with the reason for requesting the exception or extension

•            A date when the SNF believes that it will again be able to submit SNF QRP data and a justification for the proposed date

•            Any other documentation supporting the rationale for seeking reconsideration

Response from CMS

CMS will provide an email acknowledgment upon receipt of the exception and extension request. CMS will notify the CEO or CEO-designated contact provided in the request with the decision, via email.

Reconsideration Request Overview

In the Fiscal Year (FY) 2016 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule (80 FR 46459 through 46461), the Centers for Medicare & Medicaid Services (CMS) finalized the process for submitting SNF Quality Reporting Program (QRP) reconsideration requests and requests for exceptions and exemptions. The process was updated in the FY 2019 SNF PPS Final Rule (83 FR 39270 through 39271). Any SNF determined to be non-compliant with the SNF QRP requirements may be subject to a two percentage (2%) point reduction in their Annual Payment Update (APU) beginning FY 2018 and each subsequent rate year.

SNFs determined to be non-compliant following the May 15^th submission deadline will receive a letter distributed and placed into the facilities’ “My Reports” folders in the Internet Quality Improvement Evaluation System (iQIES), that includes the reason(s) for failing APU compliance. Additionally, a separate letter is distributed by the Medicare Administrative Contractors (MACs). 

News and updates regarding the distribution of the non-compliant letters and the reconsideration period may be found on the SNF QRP Spotlights & Announcements webpage in late spring/early summer. Messaging will include the method of communication for the notices, instructions for sending a reconsideration request, and the final deadline for submitting a reconsideration request.

What is Reconsideration?

Reconsideration is a request for a review of the initial CMS compliance determination for a given SNF, for a given FY.

When Would a SNF Submit a Reconsideration Request?

SNFs may file for reconsideration if they believe the finding of non-compliance is in error.

Important Note: Any exception or extension requests submitted for purposes of the SNF QRP will apply to that program only, and not to any other program CMS administers for SNFs, such as survey and certification. Exceptions related to Minimum Data Set (MDS) requirements during Declared Public Health Emergencies, including electronic submission, can be found in the Frequently Asked Questions (FAQs), Declared Public Health Emergencies – All Hazards FAQs (PDF), specifically K-5, K-6 and K-9.

Reconsideration Request Process

SNFs disagreeing with the initial determination of non-compliance and the impending payment reduction decision may submit a request for reconsideration to CMS within thirty (30) days from the date at the top of the non-compliance notification letter. CMS will not accept any requests submitted after the thirty (30) day submission deadline.

Extension to File a Reconsideration Request

In accordance with §413.360(d) (as amended by the FY 2026 SNF PPS Final Rule), an SNF that experiences an extraordinary circumstance within the 30-day reconsideration period (for example, a natural or man-made disaster) may request an extension to file a reconsideration request.

The SNF must submit the extension request to CMS within 30 calendar days of the non-compliance notification via email to: SNFQRPReconsiderations@cms.hhs.gov

Create a Reconsideration Request

Please note: The only method for submitting reconsideration requests is via email. Requests submitted by any other means will not be reviewed for reconsideration.

SNFs are required to submit their request to CMS via email with the subject line: “SNF QRP Reconsideration Request and include the SNF CMS Certification Number (CCN) (e.g., SNF QRP Reconsideration Request, XXXXXX). The request must be sent to the following email address: SNFQRPReconsiderations@cms.hhs.gov.

The email request must contain the following information:

• SNF CCN
• SNF Business Name
• SNF Business Address
• CEO or CEO-designated personnel contact information including name, telephone number, email address, and physical mailing address, i.e. not a post office box
• CMS identified reason(s) for non-compliance from the non-compliance notification letter
• Information supporting the SNF’s belief that the finding of non-compliance is in error.

• The request for reconsideration must be accompanied by supporting documentation demonstrating compliance. CMS will be unable to review requests that fail to provide the necessary documentation nor accept any files that are larger than 20 MB (megabytes). Supporting documentation may include any or all of the following:

  • Proof of submission
  • Email communications
  • Data submission reports from the iQIES
  • Data submission reports from the National Healthcare Safety Network (NHSN)
  • Proof of previous waiver approvals (including disaster exceptions/exemptions)
  • Notification of the CCN activation letter to prove that the CCN was not activated by the end of the reporting quarter
  • Other documentation supporting the rationale for seeking reconsideration

  IMPORTANT:

  Never include patient information (i.e., protected health information [PHI], patient identifiable information [PII], or other Health Insurance Portability and Accountability Act [HIPAA] data) in the documentation being submitted to the Centers for Medicare & Medicaid Services (CMS) for review. Submitting resident-level data or PHI/PII may be a violation of your facilities’ policies and procedures as well as violation of federal regulations (that is, HIPAA).

  Any documentation submitted for review that contains PHI or PII will not be accepted or reviewed for reconsideration. Please redact any PHI/PII prior to sending. If any of the documents included in a reconsideration request contain PHI/PII, the entire request will be rejected.

  Review Data Submission Requirements

  Please refer to the SNF QRP Data Submission Deadlines webpage for information on data collection timeframes and submission deadlines.

  Reconsideration Request Process Timeline

  Below is the estimated CMS reconsideration process timeline for a fiscal year’s payment determination:

• June - July: CMS issues notices of non-compliance to SNFs that failed to meet quality reporting requirements via a letter sent using the following methods:
  • The Internet Quality Improvement and Evaluation System (iQIES)
  • The Medicare Administrative Contractor (MAC) via,
    • The United States Postal Service (USPS) or
    • Email distribution
• July - August: Reconsideration requests are due to CMS by the date indicated on the notification of non-compliance from CMS.
• July - August: CMS provides an email acknowledgment within five (5) business days upon receipt of reconsideration request.
  • Please Note: The SNFQRPReconsiderations@cms.hhs.gov email account will send an auto-reply upon receipt of your email. This email auto-reply is not the CMS acknowledgment of receipt. If you do not receive a follow-up acknowledgment of receipt within five (5) business days, please check to ensure that the overall size of the reconsideration request does not exceed the 20 MB limit and resubmit your request prior to the deadline.
• September: SNFs are notified of the agency’s decision on the reconsideration requests via letter from the MACs and CMS.

• October: Annual Payment Update (APU) penalty will be imposed on all providers found to be non-compliant with quality reporting requirements.

  Filing an Appeal

  Skilled Nursing Facilities (SNFs) dissatisfied with the reconsideration ruling may file a claim under 42 CFR Part 405, Subpart R (a Provider Reimbursement Review Board [PRRB] appeal). Details are available on the PRRB Review Instructions website. You must follow the instructions listed on that website to file with the PRRB.

  If the amount in controversy is at least $1,000, but less than $10,000, then Federal Specialized Services (“FSS”) will manage the dispute as an Intermediary Hearing. Requests for an Intermediary Hearing should be sent electronically to intermediary@fssappeals.com.

  SNF Quality Reporting Program Archives